Dina Management Pty Ltd
Effective Date: 15 December 2025
Reporting Period: Financial Year: 1 July 2024 – 30 June 2025
1. Introduction
This Modern Slavery Statement is made in compliance with the Modern Slavery Act 2018 (Cth), which requires certain entities to report on actions taken to address modern slavery risks within their operations and supply chains.
At Dina Management Pty Ltd, we are committed to ensuring that our business activities are free from any form of modern slavery, including forced labour, human trafficking, and child labour. This statement outlines our actions taken during the 1 July 2024 – 30 June 2025 to assess and mitigate the risks of modern slavery within our business and supply chains.
2. Company Structure, Operations, and Supply Chains
2.1 Company Structure and Operations
Dina Management is a licensed financial services firm specialising in listed equities (stocks), corporate bond distribution, securities, proprietary managed investment schemes, and custodial and depository services.
2.2 Supply Chains
Our supply chains involve a range of critical service providers that support our operations, ensuring efficient and secure financial transactions, technology infrastructure, and the day-to-day functioning of our business. These suppliers provide essential goods and services, including:
- Office Suppliers: Supporting the infrastructure required for our physical offices, including office supplies, furniture, and facilities management.
- Financial Service Providers: Such as our clearing and settlement provider (Austraclear), which facilitates secure settlement of corporate bond transactions.
- IT Service Providers: Companies providing technology infrastructure for transaction processing, data security, and client information management systems.
- Professional Services: External auditors, legal advisors, and accountants providing compliance and legal support.
We recognise that modern slavery risks may occur at any stage of the supply chain, including in lower-tier suppliers. We actively assess these risks through supplier due diligence, audits, and ongoing monitoring. We engage with our suppliers to ensure they adhere to our Code of Conduct and modern slavery policy, and we require them to demonstrate compliance with ethical labour practices as a condition of doing business with us.
3. Actions Taken to Address Modern Slavery Risks
3.1 Due Diligence and Risk Assessment
We acknowledge that modern slavery may be present in various sectors, and certain industries or regions may be more susceptible. As part of our risk assessment process, we have identified the following areas where we may encounter modern slavery risks:
- Labour in the supply chain: Some of our suppliers, especially those providing outsourced services or goods from regions with weaker labour protections, may face modern slavery risks.
- Third-party service providers: Risks may arise from our reliance on external partners who operate in regions with limited regulations on labour practices.
We assess these risks on an ongoing basis through regular audits, supplier questionnaires, and engagement with relevant stakeholders.
3.2 Supplier Engagement
We work closely with our suppliers to ensure they adhere to our ethical labor practices and modern slavery policies. This includes providing training and engaging in discussions about ethical labour standards.
3.3 Policies and Procedures
We have implemented the following policies to address modern slavery risks:
- Code of Conduct: Our Code of Conduct requires all employees and suppliers to uphold ethical labour practices and reject modern slavery.
- Modern Slavery Policy: We have introduced a Modern Slavery Policy that outlines our stance on modern slavery and defines our approach to managing related risks.
- Whistleblower Policy: Our Whistleblower Policy allows employees and third parties to report any concerns about potential modern slavery practices within the company or its supply chain.
3.4 Supplier Audits and Monitoring
We conduct regular supplier audits and request supplier certifications to ensure compliance with modern slavery prevention policies. We also maintain open channels of communication with suppliers to address any potential issues promptly.
4. Effectiveness of Actions Taken
We assess the effectiveness of our actions by:
- Supplier Feedback: We collect feedback from suppliers and business partners on their practices related to modern slavery.
- Internal Audits: We conduct internal audits to evaluate whether suppliers are adhering to our Modern Slavery Policy.
- Key Performance Indicators (KPIs): We track KPIs related to modern slavery, such as the number of supplier audits conducted and the percentage of suppliers meeting our ethical labour standards.
5. Future Plans
We are committed to improving our efforts to combat modern slavery in the coming year. Our future initiatives include:
- Expanding Supplier Audits: We plan to extend our audit program to include more suppliers, particularly those in high-risk regions.
- Collaboration with NGOs: We will explore partnerships with non-governmental organizations (NGOs) to further our understanding of modern slavery risks and how to mitigate them.
- Enhanced Employee Training: We will provide additional training for our employees and management teams on recognising and addressing modern slavery risks.
6. Approval and Sign-Off
This Modern Slavery Statement was approved by the Board of Directors of Dina Management Pty Ltd on 15 December 2025.
Finlay Campbell, CEO, BSC, CIMA
15 December 2025